AGP lawyers have a solid track record in tax advice and tax dispute resolution. Professional excellence and effective teamwork is what ensures for our clients competent planning, outstanding transaction support and vetting for compliance with the RF tax legislation, as well as representation before various authorities.
Our professionals know all the ins and outs of Russian taxation and effectively use international standard operating procedures. This enables them to provide competent management of tax risks, develop legal solutions to set up holding companies, financial and trading vehicles. To make sure it delivers sure-fire solutions, AGP develops recommendations based on recommendations and experience of foreign tax consultants, among whom are experts from various jurisdictions such as Cyprus, Switzerland, Luxembourg etc.
The Firm provides legal services to foreign investors, advice on local taxation and recommendations on the use of controlled foreign companies.
Representation in tax audits and disputes
- settlement and litigation
- drafting of responses to requests from the tax authorities
- litigation outcome prediction
- representation in litigation over tax refunds
Transfer pricing (TP) services
- transfer pricing risk analysis for specific contracts or the company's operations across the board
- identification of controlled transactions
- assistance in TP tax audits
- TP procedural paperwork
- Tax risk identification and advice
- legal analysis of tax risks
- tax advice for any situation and tax burden minimization
- corporate restructuring paperwork
Anti-offshore package compliance and international tax planning
- offshore investment recommendations, as well as business tax planning advice to foreign companies in the RF
- advice on international business structuring under double taxation agreements
- identification of foreign entities subject to de-offshorization
- paperwork on controlled foreign companies
Successful defense of the tax agent in a dispute with tax authorities over applicability of provisions of a double taxation treaty.
Reorganization of the companies aimed at mitigation of adverse impact of the legislation on controlled foreign companies.
Foreign company branch
Obtaining a tax authority’s determination that the management fees paid to a Russian subsidiary for carrying out management functions were economically justified deductible expenses for the profit tax purposes.
Major oil trader
Advice on how to avoid having a permanent establishment in Russia.
Economic justification of expenses on product quality compliance control at a foreign supplier’s factory.